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Among the various transfer pricing methods, the profit split method (PSM) is now under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In a new book, The Future of the Profit Split Method, notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy.

NERA Managing Director Dr. Harlow Higginbotham and Director Dr. Vladimir Starkov contributed the chapter titled “Application of the Profit Split Method” to this book.